MICHAEL COMPANY, A FIRM IN THE BATTERY SALES, SERVICE AND RECYCLING BUSINESS, AS WELL AS FROM TIME TO TIME ENGAGED IN MANUFACTURING BATTERIES (LEAD-ACID STORAGE BATTERIES), OPERATED AT FOUR SITES IN DAVENPORT AND BETTENDORF, IOWA. ALL FOUR SITES WERE CONTAMINATED EXTENSIVELY WITH LEAD. EPA INCURRED COSTS FOR A REMOVAL ACTION AT ONE OF THE FOUR SITES, AND INCURRED COSTS TO INVESTIGATE AND SAMPLE AT THE OTHER THREE. THIS CASE SEEKS TO RECOVER THE COSTS, AND SEEKS PENALTIES FOR NON-COMPLIANCE WITH EXISTING SECTION 106 ORDERS FOR THREE OF THE SITES.